On 18 November 2020, parliament passed amendments to the Tax and Social Security Procedure Code at first reading, which aims to ensure the payment of withholding tax on cross-border payments and the effectiveness of tax control in the event of payments being made where the grounds for applying a relief under a double taxation agreement have not been demonstrated.

The Government imposed a fine of BGN 15,000 for hidden income abroad. In case of late application for tax treaty relief from the withholding tax due on taxable payments to non-resident income, the sanction will be up to 5% of the unpaid tax, but not more than BGN 15,000. In case of a repeated violation, the fine is doubled to 10 percent, but not more than BGN 30,000.